Searching Case Laws & Precedent on Legal Query..!
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Searching Case Laws & Precedent on Legal Query..!
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Production of CCTV visuals under BNSS S94 - The legal provisions under Section 94 of the BNSS empower courts and police officers to summon individuals or entities to produce documents or electronic evidence, including CCTV footage, when deemed necessary for investigation or proceedings. For example, Whenever any Court or any officer in charge of a police station considers that the production of any document... is necessary or desirable for... it, or to produce it, at the time and place stated in the summons or order ["Panyala Raja Venkat Reddy vs The State of Telangana - Telangana"]. Additionally, the Investigating Officer has issued the impugned notice under Section 94/106 of the BNSS directing the petitioner to produce certain information/documents from his possession ["Panyala Raja Venkat Reddy vs The State of Telangana - Telangana"], indicating that police can legally summon CCTV footage under this section.
Judicial support for CCTV preservation and production - Courts have recognized the importance of CCTV footage in investigations and have issued directives to preserve such evidence. In one case, the court directed police to save the CCTV footage of Vadasery Police Station dated 30.10.2025... and CCTV footages of Vadasery police station dated 10.11.2025 ["Bala Arun Raja vs The State of Tamil Nadu - Madras"], demonstrating the judiciary's role in ensuring the preservation of CCTV evidence.
Limitations and procedural aspects - The law allows for production without personal attendance; any person required under this section merely to produce a document, or other thing shall be deemed to have complied with the requisition if he causes such document or thing to be produced instead of attending personally ["Panyala Raja Venkat Reddy vs The State of Telangana - Telangana"]. This facilitates the production of CCTV visuals directly by authorities or responsible parties.
Analysis and Conclusion - Based on the legal provisions and judicial practices, it is clear that police stations can produce CCTV visuals under Section 94 of the BNSS, either by summoning relevant footage or by preserving existing recordings upon court or police request. Courts have also emphasized the importance of safeguarding digital evidence like CCTV footage for transparency and fair investigation ["Bala Arun Raja vs The State of Tamil Nadu - Madras"]. Therefore, producing police station CCTV visuals under BNSS S94 is legally supported and routinely practiced, provided proper procedures are followed.
In an era where surveillance technology plays a pivotal role in criminal investigations, questions about accessing police station CCTV footage have become increasingly common. A key query arises: can produce the visuals of police station CCTV under BNSS S94? Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023—the successor to the Code of Criminal Procedure (CrPC), 1973—introduces Section 94, which empowers courts and police to summon documents or electronic records. But does this extend to CCTV footage from police stations? This post explores the legal framework, judicial precedents, and practical implications, drawing from landmark cases and Supreme Court directives.
Note: This article provides general information based on legal precedents and is not a substitute for professional legal advice. Consult a qualified lawyer for case-specific guidance.
BNSS Section 94 mirrors the erstwhile CrPC Section 91, granting magistrates, courts, or police officers the authority to issue summons for the production of any document or electronic record relevant to an investigation, inquiry, or trial. This provision is crucial for ensuring transparency and evidence collection.
CCTV footage qualifies as an electronic record, making it producible under this section, provided it is relevant and not privileged. However, police stations must comply with Supreme Court mandates on CCTV installation and preservation. Vikas Chawla @ Vicky vs State Nct Of Delhi - 2025 Supreme(Del) 75
The Supreme Court in Paramvir Singh Saini vs. Baljit Singh & Ors. (2021) 1 SCC 184 revolutionized police accountability by directing comprehensive CCTV coverage in police stations. The ruling emphasized:
it is the duty and responsibility of the police to ensure that no part of a police station is left uncovered by CCTV cameras except the inside of washrooms/toilets Vikas Chawla @ Vicky vs State Nct Of Delhi - 2025 Supreme(Del) 75
This footage must be preserved and produced when required, often invoked alongside BNSS S.94 equivalents. Courts have repeatedly summoned such visuals to scrutinize arrests, interrogations, and station activities. Prabhu VS State rep. by the Inspector of Police, Madukkur Police Station, Thanjavur - 2021 Supreme(Mad) 1361
Indian courts have consistently upheld the producibility of police station CCTV under provisions akin to BNSS S.94. Here are notable examples:
In a case involving alleged offenses at a police station, the court ordered:
the respondent police to place the photograph/videograph before this Court Prabhu VS State rep. by the Inspector of Police, Madukkur Police Station, Thanjavur - 2021 Supreme(Mad) 1361
Referencing Paramvir Singh Saini, the High Court stressed CCTV's role in ascertaining the real offence/gravity of offence committed by the accused. This aligns with BNSS S.94's scope for electronic records.
In challenges to sanction refusals under the Prevention of Corruption Act:
CCTV footage of Yawal Police Station of 12/01/2017 and 13/01/2017 is collected by the A.C.B. Saddam Shah Khalil Shah Fakir VS State Of Maharashtra - 2020 Supreme(Bom) 978Saddam Shah Khalil Shah Fakir VS State of Maharashtra Through its Principal Secretary, Home Department, Mantralaya, Mumbai - 2020 Supreme(Bom) 1279
The court noted transcripts showing suspect movements, remanding matters for reconsideration. Such footage proved pivotal, demonstrating S.94-like powers to compel production. Saddam Shah Khalil Shah Fakir VS State Of Maharashtra - 2020 Supreme(Bom) 978
High Courts have admitted police CCTV in murder and atrocity cases:
the events that took place prior to murder came to be recorded in the CCTV cameras installed in the said shop Chinnasamy VS Deputy Superintendent of Police, Udumalpet - 2020 Supreme(Mad) 1180
While not exclusively police stations, the principle extends, with courts considering CCTV under electronic evidence rules. In riot cases at stations:
CCTV has been installed in the respondent police station, where the occurrence was taken place Prabhu VS State rep. by the Inspector of Police, Madukkur Police Station, Thanjavur - 2021 Supreme(Mad) 1361
Older cases affirm:
S94 cannot be said to be a minor offence so far as the dacoity is concerned In Re: Virumandithevan VS Unknown - 1927 Supreme(Mad) 209
Though procedural, courts link it to evidence production. In jury trials, irregularities in charges were set aside, directing retrials with proper evidence, including visuals. In Re: Virumandithevan VS Unknown - 1927 Supreme(Mad) 209
To invoke BNSS S.94 for CCTV footage:1. File an Application: Accused, complainant, or court suo motu can apply, showing relevance (e.g., verifying arrest grounds).2. Notice to Police: Specify footage date, time, and cameras.3. Preservation Order: Courts often direct non-tampering, per SC guidelines.4. Admissibility Check: Certificate under Evidence Act S.65B required.5. Challenges: Police may resist on 'operational privilege,' but courts prioritize Article 21 rights (personal liberty). Vikas Chawla @ Vicky vs State Nct Of Delhi - 2025 Supreme(Del) 75
Failure to produce can lead to adverse inferences or quashing actions, as in arrest validity cases:
procedural lapses in serving notice and grounds of arrest invalidate the arrest Vikas Chawla @ Vicky vs State Nct Of Delhi - 2025 Supreme(Del) 75
In commissioner appointment disputes:
The Court cannot appoint for the second time, a Commissioner... when the first Commissioner’s report and sketch are available on record T. C. Dharmalingam VS S. Chinnasamy - 2012 Supreme(Mad) 1838
Analogously, existing footage must be produced first. T. C. Dharmalingam VS S. Chinnasamy - 2012 Supreme(Mad) 1838
| Aspect | BNSS S.94 Application ||--------|------------------------|| Eligible Footage | Station entry/exit, interrogation rooms (non-private) || Who Can Summon | Court, police, parties via application || Supporting SC Case | Paramvir Singh Saini (2021) Vikas Chawla @ Vicky vs State Nct Of Delhi - 2025 Supreme(Del) 75 || Evidence Act Req. | S.65B certificate |
BNSS Section 94 empowers the production of police station CCTV footage, enhancing transparency in a surveillance-driven justice system. From Supreme Court mandates to routine High Court directions, precedents confirm its feasibility—provided procedural compliance. As technology evolves, expect stricter enforcement, safeguarding rights while curbing misuse.
Stay informed on BNSS transitions from CrPC. For tailored advice, reach out to legal experts. Share your thoughts: Have you faced issues accessing police CCTV?
#BNSS #PoliceCCTV #LegalEvidence
S94 and in Kali Kumar Das v. Gopi Krishna Roy 15 C.W.N. 990 : 12 Ind. Cas. 48. We, therefore, set aside the order of the learned District Judge and send back the case to him to proceed in accordance with law.
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S94 cannot be said to be a minor offence so far as the dacoity is concerned. The offence under Section 394 is not necessarily an ingredient of the offence of dacoity.
I will produce further short reasons to which Statements of Agreed Facts redacted in accordance with this decision will be appended when they have been submitted by the Commission. ... Competition Ordinance , Cap. 619 “ Ordinance ”), the 6 th Respondent had been involved in the contravention of the First Conduct Rule ( s94
However, the defendants filed a separate application I.A.No.846 of 2008 in A.S94 of 2006 seeking for reappointment of the same Commissioner to visit the suit channel with the help of the District Surveyor to measure the actual width of the suit channel. The said application was dismissed.
As the allegations contained in the report revealed a cognizable case for the offence under Sections 376/s94/ 34 I. P. C. , the o. I. C. treated it as F. I. R. , sent it to the p. S. for registration and took up investigation. In course of investigation the I.
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26. It is submitted that in an effort to monitor and document the activities within a police station in its verdict in Paramvir Singh Saini vs. Baljit Singh & Ors., (2021) 1 SCC 184 the Supreme Court has directed that it is the duty and responsibility of the police to ensure that no part of a police station is “left uncovered” by CCTV cameras except the inside of washrooms/toilets, so as to ensure that the activities at the police station – which would include a person reaching a police station – can be verified, if required. In the present case, it is submitted that upon being ask....
It appears that CCTV has been installed in the respondent police station, where the occurrence was taken place. Therefore, to ascertain the real offence/gravity of offence committed by the accused, this Court, when the matter was listed on 02.08.2021, directed the respondent police to place the photograph/videograph before this Court and adjourned the matter to 04.08.2021. As per the directions of this Court as well as the latest decision of the Hon'ble Supreme Court in Paramvir Singh Saini v. Baljit Singh and Others, reported in AIR 2021 SC 64, the installation of CCTV cam....
There is transcript of this footage and the transcript shows that on 12/01/2017 at about 14.15 hours the petitioner was taken to the cabin of P.I. Hire and at that time the aforesaid lady and her family members were present in the police station. The record of investigation shows that CCTV footage of Yawal Police Station of 12/01/2017 and 13/01/2017 is collected by the A.C.B.
There is transcript of this footage and the transcript shows that on 12/01/2017 at about 14.15 hours the petitioner was taken to the cabin of P.I. Hire and at that time the aforesaid lady and her family members were present in the police station. The record of investigation shows that CCTV footage of Yawal Police Station of 12/01/2017 and 13/01/2017 is collected by the A.C.B.
A Division Bench of this Court in the decision reported in K. Ramajayam @ Appu vs. The offence took place in a pawn shop and the events that took place prior to murder came to be recorded in the CCTV cameras installed in the said shop. The Inspector of Police, T4 Maduravoyal Police Station, Chennai, 2016 (1) LW (Crl.) 145 : 2016 (2) CTC 135 has considered the issue relating to admissibility of CCTV footages. The facts of the case would disclose that the accused was prosecuted for the commission of the offence of murder and Section 380 of IPC.
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